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§Legal

Privacy Policy

1. Data controller

The controller of personal data processed on this website is Victorius LLC (short name — ОсОО «Викториус»), a legal entity incorporated under the laws of the Kyrgyz Republic (date of registration: 29.10.2025) and registered for tax purposes in the Russian Federation as a foreign organization: INN 9909758616, KPP 770987001, foreign-organization code 75861. Registered address: 163 Moskovskaya str., office 8, 720000 Bishkek, Kyrgyz Republic. Director: Махамадов Умид Акбаржон угли. Hereinafter — the "Operator", "we".

2. General provisions and legal framework

The Operator is an international company providing services to users across multiple jurisdictions via the VictoriusAppart website. This Policy has been prepared having regard to the applicable personal-data protection legislation, including:

  • Law of the Kyrgyz Republic "On Personal Information" No. 58 dated 14.04.2008;
  • Federal Law of the Russian Federation No. 152-FZ dated 27.07.2006 "On Personal Data" — in respect of citizens and residents of the Russian Federation and to the extent linked to the Operator's Russian tax registration;
  • General Data Protection Regulation (GDPR, Regulation (EU) 2016/679) — to the extent applicable to data subjects located in the EU/EEA.

By using the website you confirm that you have read this Policy and consent to the processing of your personal data by the Operator on the terms set out below.

3. Categories of data processed

  • Identification data: surname, name, patronymic (if any), citizenship.
  • Contact data: phone number, email address, messenger identifiers (Telegram, WhatsApp), preferred contact method.
  • Request data: property-selection parameters (country, budget, property type, purpose of purchase), content of messages sent via contact forms.
  • Data required for the transaction: identity document details; information on income sources and bank details — solely where and to the extent necessary to support the transaction and comply with financial-monitoring requirements.
  • Technical data: IP address, browser type and version, operating system, pages visited, visit time, traffic source, UTM tags, cookie and similar technology identifiers.

The Operator does not request or process special categories of personal data (racial or ethnic origin, political views, religious or philosophical beliefs, health status, sex life) or biometric data, save where such data is provided by the subject voluntarily and expressly.

4. Purposes of processing

  • handling user requests and providing consultation;
  • concluding and performing a paid services agreement for the selection and support of transactions with foreign real estate;
  • coordinating interaction with the seller (developer, owner, overseas agency) and the Operator's partners in the property's country;
  • notifying the user of new properties and offers — subject to separately expressed marketing consent;
  • improving the website and service quality (anonymised analytics);
  • complying with applicable law, including financial monitoring, tax accounting and anti-money-laundering requirements.

5. Legal bases

  • consent of the data subject expressed by active action (submitting a form, ticking a consent checkbox, sending a message);
  • conclusion and performance of a contract to which the data subject is a party;
  • legitimate interests of the Operator (website security, protection against abusive submissions, anonymised analytics) — provided such interests do not override the data subject's rights and freedoms;
  • compliance with the Operator's statutory obligations under applicable law.

6. Processing methods and security measures

Processing is performed both by automated means (CRM system, email, cloud services) and without them (paper documents). The Operator implements technical and organisational measures to protect personal data against unauthorised or accidental access, alteration, blocking, copying, distribution and destruction: encrypted transmission channels (HTTPS/TLS), access controls, activity logging, regular backups, password protection, and staff training.

7. Sharing with third parties

The Operator may engage third parties to provide services and achieve processing purposes, including:

  • hosting and cloud service providers that support website and internal-system operations;
  • web analytics and communication service providers (email, messengers);
  • legal partners, notaris, brokers and other consultants in the property's country — for transaction preparation and support;
  • banks and payment service providers — for settlements relating to services and transaction support;
  • authorised state bodies of the Kyrgyz Republic, the Russian Federation and the property's country — upon duly formalised requests.

Such third parties process personal data exclusively on the Operator's instructions, only to the extent necessary to achieve the purpose, and on confidentiality terms.

8. Cross-border data transfers

As the Operator is an international company, your personal data may be transferred to and processed in jurisdictions outside your country of residence — in particular, in the Kyrgyz Republic (the Operator's place of incorporation), the Russian Federation (the Operator's place of tax registration and processing of Russian users' requests) and in countries where properties are located (the United Arab Emirates, the Socialist Republic of Vietnam, the Republic of Indonesia). Transfers are made in compliance with applicable law and ensure an adequate level of personal data protection.

9. Retention

Personal data is stored for the time necessary to achieve the processing purposes, but no longer than:

  • 5 years after fulfilment of contract obligations — for clients with whom a services agreement has been signed (per tax and AML requirements);
  • 3 years — for potential clients who did not sign a contract;
  • until consent withdrawal — for marketing communications.

After the retention period, data is destroyed or anonymised, except where retention is required by applicable law.

10. Data subject rights

You have the right to:

  • obtain information on whether your data is processed, and on the purposes, means and methods of processing;
  • request rectification, blocking or destruction of your data if it is incomplete, outdated, inaccurate or unlawfully obtained;
  • withdraw consent to processing at any time by written notice to the Operator;
  • object to processing carried out on the basis of legitimate interests, and to marketing;
  • appeal the Operator's actions or omissions to the supervisory authority of your jurisdiction and to court.

Upon withdrawal of consent, the Operator ceases processing and ensures destruction or anonymisation of the data within the time frame established by applicable law, except where retention is required by law.

11. Cookies

The website uses cookies and similar technologies to ensure proper functioning of the website, to save your preferences (language, currency, favourites) and for web analytics. You may disable cookies in your browser settings — some website features may then be unavailable. See the separate "Cookie Policy" document for details.

12. Changes to this Policy

The Operator may amend this Policy. The current version is always available on the website at a permanent link. For material changes, the Operator will notify users via a website notice or by email.

Last updated: 08.09.2026.

13. Contacts for data-processing enquiries

To exercise your rights, withdraw consent or obtain information about the processing of your data, you may contact us:

  • by email: hello@victoriusappart.com;
  • at the Operator's registered address (see section 1);
  • via the contact form on the website.